Statement by Karen Coyle for the Panel Discussion on P3P Implementation

Online Privacy Technologies Workshop and Technology Fair

September 19, 2000U.S. Department of Commerce

Notice is an important feature of any privacy program, and it is notice that
is addressed by P3P. However, notice does not by itself provide any amount of
privacy. With P3P, it is like we now have the axle, but we are still lacking
the wheels, the cart, and the horse. We do not have a privacy solution.

Proponents of P3P claim that the notice provided by Web site privacy policies
gives Internet users a choice. This presumes that there will be comparable services
that differ significantly in their privacy statements. I see no indication that
this will be the case. The invasion of privacy is deeply entwined with the reliance
on advertising for revenue. In a highly competitive environment like the Internet
today, the winners are all under the same pressure to play the customer profiling
game.

And in the world of information, what is after all a comparable product? If
I want to read the New York Times online but I do not want to give out information
about myself to do so, reading another newspaper that doesn't require me to
sign up, say the San Francisco Chronicle, does not give me the same content.
Unlike other products, information resources tend to be unique and that uniqueness
is encouraged by our copyright laws. Where will the reader turn for a choice?

But even worse is that this approach places the burden on Internet users to
essentially shop for their own privacy. I believe that privacy should be a right,
not a bargain hunt.

I am dismayed when P3P is touted as a solution. It is only when we create
the rest of the vehicle that we will actually enhance privacy on the Internet.
There are a number of commercial products that now address this issue but my
hope is that we will turn our attention to the root of the problem and implement
a base line of privacy that is the default for all users in all situations.
Only then will privacy be a right and not a privilege enjoyed by a few.